CSRD 2025: Practical Roadmap for Companies

2025 marks an important milestone for the Corporate Sustainability Reporting Directive (CSRD): The first companies must prepare a sustainability report aligned with the ESRS standards for the 2024 financial year and publish it in 2025. Even if the law that applies in the EU has not yet been transposed into German law, this could still happen this year.

Due to the fact that the law has already come into force in the EU and many member states have already transposed it into national law, affected companies should start preparing their CSRD report at an early stage. Over 1,000 ESRS data points ensure standardized, transparent ESG disclosure and provide stakeholders (customers, banks, investors, etc.) with insights into a company's sustainability performance.

To support your CSRD report, in this blog article we show you how to create a practical CSRD roadmap. The blog article also contains further important information on CSRD implementation in 2025 and beyond.

CSRD Implementation Act 2025: How is Germany Implementing CSRD?

CSRD was already adopted as EU law in January 2023. Since then, EU member states have had 18 months (until July 2024) to transpose it into national law. Many member states have already implemented CSRD. The EU Commission initiated infringement proceedings against 17 EU Member States, including Germany, in September 2024 due to the lack of implementation.

Various law firms and auditors have analyzed how the lack of German CSRD legislation will impact the first companies affected in 2025 (see Rödl & Partner, Noerr or Taylor Wessing).

According to these analyses, it is very likely that the transposition into German law will take place this year. Companies should therefore initiate their CSRD processes and prepare a compliant report regardless of these uncertainties.

Brief Recap: When will your Company be Affected by CSRD?

The first companies that will have to publish a comprehensive sustainability report in accordance with CSRD for the 2024 financial year in 2025 are large capital market-oriented companies, that are Public Interest Entities (PIEs) with more than 500 employees, that meet at least two out of the following three criteria: balance sheet total of more than €25 million, net turnover of more than €50 million or more than 250 employees. This means that almost 15,000 companies in Germany will be subject to the CSRD reporting obligation from 2025 for the 2024 financial year.

Just 56% of the companies surveyed that have to report for the 2024 financial year have fully addressed CSRD and the ESRS

= results from a PwC study; All Hands ok Deck: CSRD reporting as the accelerator for sustainable business transformation, PwC Global AWM & ESG Research Center. So there is still a lot of catching up to do for many companies.

The following chart and our detailed blog post on the CSRD Directive show which companies will have to prepare a sustainability report from 2026, 2027 and 2028 in accordance with CSRD.

Implement CSRD: Your CSRD Roadmap

CSRD presents many companies with a variety of complex tasks. A structured project plan helps to maintain an overview. This enables close collaboration with stakeholders and distribution of tasks to various responsible parties in order to make reporting efficient and auditable.

Below, you will find an example of a project roadmap for a company that is obliged to publish a CSRD report for the 2025 financial year in the 2026 reporting year:

Step 1: Create your CSRD project plan and understand CSRD

Clarify who has the main responsibility for the CSRD report and which employees need to be involved. A project plan should then be drawn up containing most of the tasks relating to the CSRD report, including potential responsibilities and time horizons.

The CSRD project team should establish a basic understanding of CSRD and the ESRS standards at an early stage. We also recommend regularly checking the FAQs from EFRAG as you may find answers to your questions there. All other questions can be submitted here: EFRAG ESRS Q&A Platform.

As the data required for the ESRS standards is not necessarily available in the sustainability department, companies must integrate several departments as well as customers and partner companies along the entire value chain into the CSRD reporting process. It is important to inform the relevant stakeholders at an early stage and educate them about CSRD — so that everyone pulls together and knows transparently when and why certain qualitative and quantitative data is requested.

It also makes sense to talk to potential auditors at an early stage who will ultimately audit the CSRD report. The decision to integrate CSRD software, for example for data collection, should also be made.

We recommend setting up the CSRD project team and familiarizing yourself with CSRD and ESRS in the year before the financial year to be reported so that your CSRD project team can start on time. The individual roadmap steps and potential obstacles will take a lot of time, so you can ensure that you have enough time for your CSRD reporting.

Step 2: Double materiality analysis as a basis

The double materiality analysis is the heart of CSRD reporting and is defined as a central requirement by the ESRS (in particular ESRS 1, Chapter 3). It identifies the material sustainability aspects of a company. These can be significant both through direct or indirect impacts on people and the environment along the value chain (impact materiality) and through financial risks and opportunities for the company itself (financial materiality). You can read more details in our blog article: Double materiality analysis according to CSRD.

The identified material topics form the basis for the content of the sustainability report. In order to make this process successful, experts such as auditors should also be involved at an early stage. Complete documentation (on assumptions, results, methods, etc.) is essential. Given the considerable amount of time (three to four months) involved in the materiality analysis, companies that are required to report from 2025 onwards should start carrying it out immediately if they have not already done so.

The double materiality analysis should be reviewed annually and adapted to new findings, new risks, opportunities, and impacts. This means that the content of your CSRD report may change each year not only in quantitative terms (for example, by improving your ESG performance), but also in terms of content.

Step 3: ESG data and processes: Identify and close gaps

To meet the requirements of CSRD, a profound analysis of your current data and process landscape is essential. Start by mapping your existing processes for collecting, analyzing and monitoring all ESG data, such as your company's non-financial information. You should also check the extent to which these already comply with CSRD requirements.

Analyze what ESG data you already have available through other certifications (for EcoVadis, CDP and co.) and how this can help you with the CSRD report.

You can integrate your previous data into the ESG software Sunhat so that it can provide you with AI-based answers for the ESRS standards based on this data.

Compare your processes with the requirements of CSRD, including the required information areas, reporting formats and internal control mechanisms. Identify existing gaps: What data is missing? Where are weaknesses in the processes or the tools used? Distinguish between qualitative gaps, such as missing guidelines or policies, and quantitative data gaps, such as incomplete ESG figures.

The CSRD data point list contains around 70% qualitative and 30% quantitative data points — so both should be taken into account.

Document your analysis results carefully, including identified gaps and priorities for improvement. Allow approximately two to three months to initiate the necessary actions to close these gaps and fully prepare your organization for the CSRD.

One of our customers, the hygiene paper manufacturer WEPA, is currently preparing for CSRD reporting. They are using Sunhat for data collection and management:

"Collaborating with Sunhat enables us to optimally manage our internal processes and ensure the reportability and verifiability of our sustainability data. This forms the basis for facilitating the fulfillment of future reporting requirements."‍

Dr. Stefan Gräter
Director Group Sustainability

You can find precise insights into how WEPA uses Sunhat for CSRD implementation in the Experience report from WEPA.

Step 4: Implementation of the CSRD report for the 2025 financial year

Allow sufficient time for the implementation step (approx. three to seven months) to establish a robust and audit-proof CSRD reporting system.

1. Define clear responsibilities for data and processes

The implementation of CSRD requirements requires a detailed plan. Determine who is responsible for collecting, validating and sharing the required ESG data. Who collects what information, who validates the data, and who ensures that the timelines are adhered to? A clear structure is the only way to ensure that everyone involved works in a targeted manner and that a correct, CSRD compliant report is produced.

2. ESG data collection: efficient use of CSRD software

ESG software, such as Sunhat's software, not only supports you in collecting and organizing your sustainability data, but also offers functions that are important for complying with CSRD. In Sunhat you can:

• Benefit from guidance and templates
• map your double materiality analysis so that you only have to report the data that is relevant to you
• Find and use existing data more easily
• Collect data from internal and external stakeholders through customized and quick access options
• Manage tasks and assign them to responsible team members
• Cooperate with internal and external stakeholders

You can get an initial insight and further information about the software here: Sunhat's CSRD solution

We recommend that you engage with your auditors early, so that you can align on expectations and prepare your systems and your data for audit readiness.

Step 5: Create a CSRD report & have it audited

Once all the data has been collected, analyzed and validated, the creation of the final report begins. Make sure that the content is clearly structured and meets the requirements of CSRD and ESRS standards. Allow sufficient time for review loops to avoid errors and ensure high quality. Be aware, that the external auditors should provide limited assurance before the CSRD report is published for the public view.

The overall CSRD audit and the final preparation of the report typically take two to four months. Due to the novelty and complexity of the CSRD requirements, companies should account for more time for the audit process in the first reporting year.

Once all internal and external audits have been completed, you submit the report to the Federal Official Gazette as part of the annual financial statements (in the management report). The known deadlines from the German Handelsgesetzbuch (§ 325 HGB) apply: As a capital market-oriented company, this must be done within the first four months (e.g. by 30.04.2026 for the 2025 financial year), for all other companies within 12 months (by 31.12.2026 for the 2025 financial year). Those deadlines not only apply for the CSRD report, but for the entire annual reporting package (including the financial statements as well).

In the coming years, the CSRD report will also be published as a machine-readable report using XBRL tagging. You can find more information on this topic in our blog: ESRS XBRL taxonomy.

With this roadmap, you are ideally positioned to meet the challenges of the CSRD and create an auditable, standard-compliant sustainability report.

Additional Tip: Perform a Test Run before Your Mandatory CSRD Reporting

We recommend carrying out a so-called "dry run" of CSRD reporting at an early stage. Simulate the complete data collection and documentation in order to identify and eliminate potential weaknesses in the process.

A test run reveals possible gaps in data collection or quality and offers the opportunity to improve processes iteratively. You should not only check the completeness and consistency of your data, but also take into account requirements of different locations and subsidiaries.

Use the findings from the test run to implement targeted improvements and optimally prepare your company for the first mandatory reporting. The improvements from the test run can be used to ensure that the final CSRD report you produce and publish meets the requirements of the ESRS standards.